OUR CODE OF CONDUCT

Our Code of Conduct deals with how Conflicts of Interest are managed internally and the processes, procedures adopted by the Group to this end. In relation to conflicts of interest, key points to note from the Code of Conduct indicatively include:

All employees are bound by the terms of the Code of Conduct.

All employees should at all-time be in full compliance to internal policies and procedures.

Employees are advised through the Code of Conduct how to identify conflicts of interest and how to escalate these to their line management and the Compliance Department.

All employees are bound by professional secrecy. Confidential information is only to be shared if essential for performing their specific duties and responsibilities.

Non-Group related executive or non-executive roles are only possible with prior permission, unless this relates to social causes.

Employees are prohibited from personally trading using the knowledge gained from inside/non-public information.

Treating Customers Fairly is central to our corporate culture and ethos. We have a duty to act honestly, fairly, professionally and in the best interests of our clients when dealing with them. Our framework for Treating Customers Fairly is premised on six key principles as follows:

Clients should be confident that treating them fairly is central to our corporate culture and ethos;

We market products and services to our retail clients having regard to whether they are appropriate for them, based on the targeted clients' knowledge and experience;

We provide our clients with clear, fair, not misleading and not aggressive information at all times: before, during and after their trading with us;

We do not offer clients investment advice. We communicate non-client specific market information and "colour" from sources which we reasonably believe, acting diligently, are credible;

We provide high levels of client service and experience as measured by: best possible prices, speed of execution, quality of our knowledge on client enquiries. We do not promise what we cannot deliver. We are not aggressive or misleading in our dealings with clients and do not permit business or other introducers to be so either;

We are transparent on the basis that clients deal with us, especially where clients trade with us on a principal to principal basis. We advise clients of conflicts and the Over the Counter ("OTC") and non-transferability nature of our CFD product suite.